G.R. No. L-8579; March 30, 1914
THE UNITED STATES, plaintiff-appellee, vs. RUPERTO T. SANTIAGO, defendant-appellant.

FACTS:
The defendant-appellant, Ruperto T. Santiago, was an agent of the West Coast Life Insurance Company. An information was filed charging him with the crime of estafa. It was alleged that in April 1912, in Iloilo, he collected a premium of P116.62 from policyholder Felix Golez but, instead of remitting it to the company’s office in Manila as required by his contract, he appropriated the money for his own use, to the prejudice of the company. The defense raised a jurisdictional challenge, arguing that under a prior similar case (U.S. v. Cardell), the offense, involving a failure to remit funds payable in Manila, was triable only in Manila. At trial, the prosecution presented documentary evidence (the agency contract and the agent’s reports) and the defense admitted the collection and non-remittance. The defense’s evidence sought to establish that the company was indebted to Santiago for unpaid commissions on other policies, and that he retained the collected amount in good faith, believing he was authorized to do so pending a settlement of accounts.

ISSUE:
1. Whether the Court of First Instance of Iloilo had jurisdiction to try the offense.
2. Whether the evidence was sufficient to prove the defendant’s criminal liability for estafa beyond a reasonable doubt.

RULING:
1. On Jurisdiction: The Supreme Court held that the Court of First Instance of Iloilo had concurrent jurisdiction with the Court of First Instance of Manila. The offense was committed partly in Iloilo (where the collection and alleged misappropriation occurred) and partly in Manila (where the failure to remit was consummated). Where acts material and essential to the crime occur in different provinces, the courts of either province have jurisdiction. This ruling modifies the strict common-law rule and is consistent with Section 6 of General Orders No. 58.

DISPOSITIVE:
The judgment of conviction was REVERSED. The accused was ACQUITTED of the crime of estafa, with costs de oficio.